ML20099F428

Forwards Response to Samelson 841026 Comments Re Bechtel First Progress Rept on Independent Design Review.Status of Responses to Samelson Request for Documents Listed

ML20099F428
Person / Time
Site:	Clinton
Issue date:	11/12/1984
From:	Geier J ILLINOIS POWER CO.
To:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
L40-84(11-12)-L, U-0759, U-759, NUDOCS 8411260416
Download: ML20099F428 (10)

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IP CLIN 1oN POWER STATION. P.o. 80x 678. CLINToN. ILLINOIS 61727 November 12, 1984 Docket No. 50-461 James L. Milhoan

Section Chief, Licensing Section Quality Assurance Branch Office of Inspection and Enforcement Mail Stop EWS-305A.

U. S. Nuclear Regulatory Conurission

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' Washington, D. C. 20555 Subj ect: Illinois Power Company Clinton Power Station Independent Design Review Docket No. 50-461 OL

Dear Mr. Milhoan:

By letter of October 26, 1984, Mr. Samelson, Assistant Illinois-Attorney General,-submitted to the NRC Illinois' comments on the first progress report of Bechtel in the above-referenced matter. Although the letter focuses on three areas of particular concern to Illinois, it appears.that Illinois still seeks responses to other cotxaents it presented at.the meeting on October 16, 1984.

We have reviewed the comments presented by Illinois both in its October.26 letter and at the October 16 meeting. Enclosed for your information are our responses to such comments.

In its October 26 letter, Illinois also requests copies of the following documents:

(1) the Sargent & Lundy analysis of the four independent reviews I of.S&L design activities, as specified in correspondence dated October 11, 1984 from D. P. Hall to James L. Milhoan (U-0750):

(2) the " point papers" developed by Illinois Power Company in response to'the twenty engineering design areas identified by Stone &

Webster; reference D. P. Hall to James L. hilhoan dated September 28,

'.1984 (U-0741); and

.(3) each of the reviews of Sargent & Lundy design activities which are being provided to BPC in the conduct of the IDR. h j

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We have forva'ded r to Mr. Samelson a copy of'che documents.specified in item L (1) . . We have forwarded .to Mr. Samelson copies of 17 of the 20 point papers specified in item-(2). .Three of the point papers.are 1still being 1 prepared. These will.be forwarded to Mr. Samelson under

' separate cover when they are completed. We have asked Mr. Samelson to

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clarify the request' contained in item-(3).

Sincerely yours,

.Cjb'G U.' D. Geier As'sistant To The Vice President.

JDG/im Enclosure cc: IDR Standard Distribution List (w/ encl.)

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Clinton Power Station-2 Independent Design Review

' Standard Distribution' List-

. Director of Nuclear Reactor Regulation' . Richard J. Goddard, Esq. >

- ' Attn:- c Mr. A. Schwencer, Chief: . Office of the Legal Director Licensing' Branch No.-a. U. S. Nuclear Regulatory Commission R. ' Division of-Licensing . . _.

. Washington,'D.C. 20555

_, U. S. Nuclear. Regulatory Commission

Washington, D.C. :20555 ' Don-Etchison

-Director,1 Illinois Department of EJ ames G..Keppleri E Nuclear. Safety ,

, Regional Administrator' ,

.1035 Outer Park Driv. .

-Region III . ..

Springfield ,: Illinois 62704

.U. S.. Nuclear' Regulatory Commission'

'799 Roosevelt Road Allen >Samelsoni Esq..

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Glen Ellyn., Illinois ~160137 Assistant Attorney. General Environmental' Control Division-Southern Region Byron Siegel . .

l Clinton-Licensing Project Manager -500 South Second Street Mail Code 416 .

Springfield Illinois 627061

. U.' S'. Nuclear Regulatory Commission Washington, D.C.-'20555 Jean Foy Spokesperson, Prairie Alliance Fred Christianson' 511 W. Nevsda Mail Code'V-690' Urbana,-111rois- 61801-NRC Resident Office j Clinton Power Station Richard Hubbard R.R.~f3, Box 228 MHB Technical-Associates 1 Clinton, Illinois'. 61727 1723 Hamilton Averue Suite K i James L. M11hoan San Jose, California 95125

Section Chief, Licensing Section Quality Assurance' Branch -

Gordon L. Parkinson i'

Office of-Inspection and Enforcement Bechtel Power Corporation Mail Stop EWS 305A Fifty Beal Street

-U. S. Nuc3 ear Regulatory Commission- P. O. Box 3965-Washington,-D.C. 20555 San Francisco, California 94119 Richard C. Knop jRoger Heider Section Chief Sargent & Lundy Engineers Projects Section 1-C 55 East Monroe Street U. S. Nuclear Regulatory Commission Chicago, Illinoic 60603

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-Glen Ellyn, Illinois 60137 i

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< Illinois Power Responses tol

(  ; Attorney General of Illinois:

, Comments in Letter.of,10/26/84 4"

.and at Meet'ing of' 10/16/841 h[

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[(1) ~' Illinois 'Conument (p.1 of 10/26/841 letter)-

" Firstly we request an opportunity;to inspect t'ne. primary

- -documentation generated during the course of the 1DR.'; This would ,

. include"checkclists, commitment lists, review sheets, and all'other.

n Jworking files _of.3PCJin the_ conduct'of the~IDR. iWithout access to

. this documentation',' we believe the IDRJreports :are essentially; inscrutable'."

Illinois Power (IP) Response The'information to which' Illinois seeks acce'ss is available for inspection byfthe NRC. The possibility of access to;s0me information by. Illinois can be/takenLup in.the? continuing-discussions between Illinois and IP and'should be resolved-between them. Any Illinois access to information'would, however, necessarily be limited to such items as minutes of Bechtel meetings with Sargent & Lundy (S&L),'re' quests for information, and information prnvided by S&L (excluding proprietary information).

While-a subject is being reviewed by Bechtel, in order.to avoid any outside' influence on or impediment of Bechtel's efforts, only the ENRC audits should have access to " check' lists, commitment lists.

review sheets, and all other working files-of BPC (2) Illinois Comment (p.1 of 10/26/84 letter)

~" Secondly, it is unclear whether substantive discucsions between BPC and Sargent & Lundy or Illinois Power Company vill be held during ' working meetings' that may occur after an observation has been reported. We believe that any such discussions should be subject to the prior notice and opportunity-to-attend requirements of the-IDR protocol."

IP Response Whether before or after an observation has been reported, substantive discussions between Bechtel and IP or S&L can take place only at a public meeting-subject to the notice requirements of paragraph 3 of the Protocol or in telephone conversations subject to. paragraph 6 of the Protocol proposed in IP's letter of 11/1/84, as modified.and approved by the NRC lettar of 11/6/84.

Discussions in the course of obtaining'information or clarification of requests for information are, of course, subject to paragraph 2 of the Protocol.

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In accordance with-the.NRC's request (transcript of 10/16/84 meeting page _149),' information flow between Bechtel and S&L will-be an item on the agende of the public meeting scheduled for

' November' 13, 1984. Bechtel will also respond at the meeting to the.

NRC comment resulting from its program plan implementation inspection that Bechtel procedures "should clearly identify protocol requirements relative to discussions of substantive technical matters with revicwee organizations.". (IE Report No.

50-461/84-39, Attachment 1, at page.2).

(3) Illinois Comment (pp. 1-2 of 10/26/84 letter)

" Thirdly, we are especially concerned about Sargent & Lundy's_ role in the'IDR. Recent Observation Reports confirm-our. initial impression that'it is Sargent & Lundy, rather than the independent

' reviewer, who is conducting important aspects of the IDR program.

See, for example, observation report no. 10, dated October 12, 1984:

'S&L should provide an explanation of why these discrepancies occurred, and an assessment of their safety significance. S&L should identify similar applications of using interruptable-control power in'the control circuits of other safety related systems and verify that the design commitments are implemented in the design to ensure design adequacy.';

and observation report ro. 11, dated October 12, 1984:

'S&L should provide an explanation of why these discrepancies occurred, and an assessment of their safety significance. S&L should review other layout drawings and evaluate the implication on other systems and areas if similar discrepancies occur elsewhere.'

k'e would be interested in learning whether, in the judgement of NRC, the IDR is being conducted with the requisite independence and

' freedom from outside influence', on the scope of the reviewer's work, in the processing of observations, the determination of their safety significance, the need for more intensive review, and in the valuation for underlying, root causes or broader implications.

. (See IDR Program Plan, Rev. 1, page 3, pat. 2 and page 6, par.l.)"

IP Response Notwithstanding Illinois' expressed concern, nothing in the cited Observation Reports (or any other Observation Reports) would indicate.that S&L, rather than Bechtel, is " conducting important aspects of the IDR program." It is fully appropriate for Bechtel, in an open process, to ootain both factual information from S&L and S&L's explanation or position concerning any subject. In fact, Bechtel would be remiss in attempting to finalize its views on any subject without obtaining such information or explanation. This is

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no d'ifferent' than the . mechanisms NRC itself employs. in. developing - -

!a' complete record lin'the: course of assessing theJaignificance of..

a ' Lany11dentified concern and any' need for corrective action. : The' use-t 'l

,of such-mechanisms do.sLnot in'any way affect _"the requisite-  ;

-independence-and ' freedom from outside-. influence'" of.the IDR.

1(4) ~ Illino'is Comment (Trb of c 10/16/84, p. 132)

'"Mr. Hubbard: .

Jim,' following on from what Allen was~saying.-the progress reports don't really.have anything.in.the way of-

-underlying; documents.-

1By.that, the checklists aren'tLthere, the. commitment lists and the detailed ~ procedures-that are being used. So if one wishes to speed' up the final review, then one suggestion w6uld be=that these--

underlying documents should be.provided at.an earlier time.

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And that also' ties into --Lone.of the purposes of today's meeting is.to'get. feedback. And it's very' difficult to provide feedback, when the. underlying' documents'aren't provided."

. IP Response

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a This Illinois request is' set forth more specifically in its letter of 8/26/84 (see Illinois Comment (1) above) and is responded to'

-above.

-- (5) Illinois Comment (Tr. of 10/16/84, p. 134)

"Mr. Hubbard:- Another general area that in terms of the checklists and commitments lists, there have been many references to the FSAR, and I didn't hear any references to the PSAR.

And so.a question I would have is: What is the role of the PSAR-if any in the review?"

IP Response As noted at' page 9 of the IDR Program Plan, the source of .

commitments being reviewed by Bechtel to identify commitments include the FSAR and IP responses to NRC questions on the FSAR.

Since the FSAR contains a more detailed and updated description of design and commitments than the PSAR, the PSAR is not being reviewed in the IDR.

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s (6) Illinois Comment (Tr. of-10/16/84, p.'134)

"A third:areafis.in Mr. Geier's letter and some of the comments by Mr. Powell, it.was mentioned that aspects of the HVAC ' system were being looked cc.- And we would like to know specifically what aspects of the heating, ventilating, and air conditioning' systems-

-will be looked at?"

IP Response Portfons of the HVAC related to'the systems.within scope-of the IDR are being reviewad.- From this, a reasonable assesement can be made:

of key' elements of HVAC design.. Specifically, the following will be reviewed:

HVAC duct supports HVAC equipment; specification

' Fire protection _ dampers Seismic II/I design-Equipment environmental qualification

' Heat load and seismic criteria IDR. system design process related to HVAC.

(7) Illinois Comment (Tr. of 10/16/84, p. 134)

"A fourth area is that there was mention made that samples were t

being used within some of the vertical reviews. And we think that the report should set forth the basis for the sampling size determined by Bechtel to be appropriate and then within that-the reasons why particular items were selected, whether it's based on engineering judgement, statistics, or any. other method that they are using."

IP Response-The Final Report will, indeed, cover the subject of sample

. selection, as to the basis, eelection, and size. The method of scmpling is based upon use of engineering judgement, by qualified reviewers. In this, a large number of significant elements are reviewed and evaluated, in accordance with the Program Plan. When results-indicate additional review should be performed, the IDR takes more samples or causes others to do so. The scope selection l

provides good coverage of a broad spectrum of design, and was >

l discussed in Bechtel's letters BLI-04, 6/25/84 and BLI-li, 8/17/84.

This sampling methodology for reviews of design engineering work of nuclear power plants has been well established by other independent design reviews.

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. , l (8)!= illinois Comment (Tr. of 10/16/84,-pp."134-135)-

(From-line:22 of;page-134Tto:line 11 of.pageL135, Illineis comments ~ -

on S&L's role in the,IDR).

IP Response,

_ This Illinois comment'is set-forth in more~ detail'in its letter'of-f8/26/84-(see Illino'is Comment-(3) above):and.is reroponded to above.

(9)L Illinois-Comment-(Tr. of 10/16/84, p. 135)

"Also'having'to-do with S&L's participation, that we wanted to.be sure that>the field design efforts were_being. covered; for example, small bore piping and things of that sort'thatLare done at the~ .

-site."

IP Response i-The Clinton IDR'will cover review.of design 1 engineering work performed at the site,-including small bore piping design.

(10) Illinois Comment'-(Tr. of 10/16/84, pp. 135-37)-

(From line 16 of-page 135 to.line 5.of page 137, Illinois comments at length on the'use of the words " safety significant condition"

, and on the documenting of deficiencies or deviations that do not meet the threshold of potential observations.)

IP Response In IP's letter of September 27, 1984 to the NRC, we have previously pointed out the limited impact on the conduct of the IDR of whether i or not an observation is categorized as " safety significant."

-Bechtel discussed the definition of " safety significant" at pages '

40-42 of the transcript of October 16, 1984. We see no reason to change that definition.

At pages 43-57 of that transcript, Bechtel explains how deficiencies or deviations below the threshold of potential obcervations are reflected on review sheets and in the appendices of the IDR final report. In addition, Bechtel's letter to IP of October 29, 1984, states that it has initiated actions which "will provide more complete responses to questions regarding discrepancies which the IDR Team regards as too minor to be treated as Potential Observations." 'We have asked Bechtel to include on the, agenda of the public meeting scheduled for November 13, 1984, a brief. description of those actions. Bechtel will also respond _at the meeting to the NRC comment that "IDR project procedures should provide clear guidelines for determining the threshold between inconsequential discrepancies, such as minor calculational math errors, and-observations or potential observations." (IE Report

'No. 50-461/84-39 Attachment 1, page 1).

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. 1.. c -6 (11) Illinois Comment -(Tr. of 10/16/84, p. 137)

Moving on to process terrors of deviationa. It's not apparent to me that a process deviation would ever result in an observation by the criterin that's being used. And, you know, it obviously is the same way with accumulation of them."

IP Response Task 3 of the IDR Program Plan (pages 14-16) provid'es for review of the design process and culminates in Subtask 3G, which is the identification of potential Observations resulting from:such review. In addition, Bechtel's letter to IP of October 29, 1984, states that it.has initiated actions to give " additional attention to the evaluation of_ design process." We have asked Bechtel to include on the agenda of the public meeting' scheduled for November 13, 1984, a brief description of those actions.

(12) Illinois Comment-(Tr. of 8/16/84, p. 137)

"In terms of calculations, there are things such as veights, orientations, and so forth that can affect calculations. And apparently orientations are things like valve orientations and so forth that are'beit.g looked at as part of walkdowns."

"But I wonder if-other things that are central to calculations, such as weights and thingo of that sort, are being verified."

IP Response The IDR team is. reviewing inputs to calculations which it judges to be most significant, including valve weights. Reference may be made to the viewgraphs accompanying the stenographic report of the October 16 Progress Meeting, for comprehensive listings of elements reviewed in calculations.

(13) Illinois Comment (Tr. of 8/16/84, op. 137-138)

" Moving on to the horizontal review. It doesn't seem to me that l what is going on will allow us to make a finding that the l procedures applicable to the Clinton station are being followed.

We are going to have some knowledge that procedures were or were not followed at Fermi or Byron or other things. But if the desira of a horizontal. review is to say that the process being used at Clinton was in accordance with the Clinton commitmetts and procedures, I don't see how 'one rea::hed that conclusion on the things that are being looked at because I don't see the tie-in between the horizontal and vertical review so that we see that we can reach that conclusion.

And I would agree with a NRC comment that if you find something in the horizontal review at other plants that's applicable to Clinton, it should be looked at for Clinton; in other words, it should go beyond the three systems."

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7 IP Response-At pages 812 97 of the transcript of the meeting of October 16, ,

Bechtc11 described in some detail the manner in which it is Leonducting its horizontal review, including the interrelationship b'etween the horizontal review and the. vertical review of-three specific systems. Illinois' comments do not raise any questions which were not adequately answered in Bechtel's-pcesentation.

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